Australian Government - Australian Education International

National Code Part D, Standard 10

Monitoring course progress

 

Explanatory guide for Standard 10

 

Frequently asked questions on this page:

 

 

Registered providers systematically monitor students’ course progress. Registered providers are proactive in notifying and counselling students who are at risk of failing to meet their course progress requirements. Registered providers report students, under section 19 of the ESOS Act, who have breached the course progress requirements.

 

 

Monitoring the course progress of students allows the provider to identify and offer support to those at risk of not progressing. Students who are not making satisfactory course progress are reported to the Secretary of the Department of Education through PRISMS.

Key requirements for all sectors:

 

  • The progress of each student is monitored, recorded and assessed.
  • The provider has documented course progress policies and procedures.
  • The provider assesses each student at the end point of each study period according to its course progress policy.
  • The provider has an intervention strategy that identifies and assists students who are at risk of not making satisfactory course progress.
  • Where a provider has assessed the student as not meeting satisfactory course progress, the provider informs the student in writing of its intention to report the student and that he or she is able to access the provider’s complaints and appeals process within 20 working days.
  • The provider notifies the Secretary of the Department of Education through PRISMS of the student not achieving satisfactory progress after the appeals process (if actioned) is finalised and upholds the provider’s decision to report.
  • All providers are required to have documented course progress policies and procedures. A generic course progress policy may be appropriate for more than one course. Courses that require additional or varied progression rules will necessitate a separate course progress policy.
  • Providers must assess course progress at the end point of every study period.
  • All providers must have a documented intervention strategy, which must be made available to staff and students. At a minimum, the intervention strategy must be activated where the student has failed or is deemed not yet competent in 50 per cent or more of the units attempted in any study period. Providers may choose to intervene at any point before the end of a study period if outlined in their course progress policy and/or intervention strategy.
  • Where the registered provider has assessed the student as not achieving satisfactory course progress, it must notify the student in writing of its intention to report the student for not achieving satisfactory course progress. The written notice must inform the student that he or she is able to access the provider’s complaints and appeals process and that the student has 20 working days in which to do so.

 

Compliance tips

For a provider to show it is complying with Standard 10, it may need some of the following as evidence:

  • a documented policy and procedure for monitoring, recording and assessing course progress
  • a documented intervention strategy for students at risk of not making satisfactory course progress
  • evidence of assessing students’ course progress at the end of each study period
  • documented evidence in students’ files of the intervention measures implemented for them
  • evidence in students’ files of written notice informing the students that the provider intends to report them for not making satisfactory progress and advising them that they are able to access the provider’s complaints and appeals process within 20 working days
  • evidence of an appeal in accordance with Standard 8, if a student appeals; and
  • evidence in the student’s file of final reporting to the Department of Education via PRISMS.

 

What this standard involves

 

10.1  

The registered provider must monitor, record and assess the course progress of each student for each unit of the course for which the student is enrolled in accordance with the registered provider’s documented course progress policies and procedures.

 

  • The registered provider must have documented course progress policies and procedures.
  • Monitoring, recording and assessing the course progress must occur for each unit of the course. This also relates to Standard 9.1 and 9.2.
  • ‘Monitoring’ refers to an active checking of course progress; ‘Recording’ means that there must be a documented record of the student’s achievement within each unit; ‘Assessing’ requires the provider to consider a student’s demonstrated achievement, progress or competency.

 

10.2  

The registered provider must have and implement appropriate documented course progress policies and procedures for each course, which must be provided to staff and students, that specify the:

a.

requirements for achieving satisfactory course progress

b.

process for assessing satisfactory course progress

c.

procedure for intervention for students at risk of failing to achieve satisfactory course progress

d.

process for determining the point at which the student has failed to meet satisfactory course progress; and

e.

procedure for notifying students that they have failed to meet satisfactory course progress requirements.

 

  • Providers must have and implement course progress policies and procedures for each course. These policies must be made available to staff and students. A generic course progress policy may be appropriate for more than one course. Courses that require additional or varied progression rules will need a separate course progress policy.
  • Students should be made aware that they will be reported to DIBP if they do not maintain satisfactory course progress. Best practice in implementing Standard 10.2 could be to provide a generic step-by-step guide on course progress, intervention and reporting.
  • Course progress policy is determined by the provider, unless it chooses to implement the Department of Education–DIBP approved course progress policy and procedures under Standard 11. Standard 11 allows any provider to choose to implement the Department of Education-DIBP approved course progress policy and procedures. However, exemption from attendance monitoring requirements under the the Department of Education–DIBP approved course progress policy and procedures only applies to vocational education and training (VET) courses.
  • At a minimum, the intervention strategy must be activated where the student has failed or has been deemed not yet competent in 50 per cent or more of the units attempted in any study period. A provider may choose to activate an intervention strategy at any point before the end of the study period provided this is outlined in its course progress policy and/or intervention strategy.

After all complaints and appeals processes are finalised and a student is deemed to have failed to meet satisfactory course progress, the provider must report this via PRISMS.

 

The registered provider must assess the course progress of the student in accordance with the registered provider’s course progress policies and procedures at the end point of every study period.

 

  • Providers assess students in accordance with their course progress policies and procedures at the end point of each study period. Providers must be able to make a judgement as to whether a student is:
    • making satisfactory course progress
    • at risk of not making satisfactory course progress, and therefore an intervention strategy must be implemented; or
    • not making satisfactory course progress after an intervention strategy has been completed, and after all complaints and appeals processes have been finalised. At this time the student is reported to the Secretary of the Department of Education via PRISMS.

 

10.4  

The registered provider must have a documented intervention strategy, which must be made available to staff and students, that specifies the procedures for identifying and assisting students at risk of not meeting the course progress requirements. The strategy must specify:

a.

procedures for contacting and counselling identified students

b.

strategies to assist identified students to achieve satisfactory course progress; and

c.

the process by which the intervention strategy is activated.

 

  • The provider must make its intervention strategy available to all staff and students.
  • The provider must inform students if they have been identified as failing or at risk of failing to meet course progress requirements.
  • The intervention strategy must specify what additional support will be provided to students at risk of not meeting satisfactory course progress requirements. Strategies for assisting students at risk could include, but are not limited to, the student:
    • attending academic skills programmes
    • attending tutorial or study groups
    • receiving individual case management
    • attending study clubs
    • attending counselling
    • receiving assistance with personal issues which are influencing progress
    • receiving mentoring
    • being placed in a suitable alternative subject within a course or a suitable alternative course; or
    • a combination of the above and a reduction in course load.
  • An intervention strategy could be activated by:
    • a letter to the student
    • personal contact with the student by a suitably authorised staff member
    • contact with the student by the course counsellor/convenor; or
    • other methods in accordance with the provider’s policy.
  • Documentary evidence of the intervention measures implemented should be kept in each student’s files.

 

10.5  

The registered provider must implement the intervention strategy for any student who is at risk of not meeting satisfactory course progress requirements. At a minimum, the intervention strategy must be activated where the student has failed or is deemed not yet competent in 50 per cent or more of the units attempted in any study period.

 

  • Providers develop a documented intervention strategy that includes procedures for identifying students at risk of not meeting satisfactory course progress and for activating the intervention strategy.
  • The intervention strategy is for students at risk who, at minimum, have failed or are not competent in 50 per cent or more of the units in a study period. The point at which an intervention strategy is put in place should be stipulated in the provider’s course progress policies and/or in its intervention strategy.
  • A provider may implement the intervention strategy at any point before the end of a study period. The point at which an intervention strategy is put in place must be stated in the provider’s course progress policies and/or in its intervention strategy. This allows providers in all sectors the flexibility to adapt intervention strategies to their particular circumstances.
  • Evidence of the intervention measures employed for the student should be kept in the student’s file.

 

10.6 

Where the registered provider has assessed the student as not achieving satisfactory course progress, the registered provider must notify the student in writing of its intention to report the student for not achieving satisfactory course progress. The written notice must inform the student that he or she is able to access the registered provider’s complaints and appeals process as per Standard 8 (complaints and appeals) and that the student has 20 working days in which to do so.

 

  • Providers are only able to initiate the reporting process for a student not making satisfactory course progress after an intervention strategy has been implemented and the student has been allowed time for the intervention to run its course.
  • Providers must report students in accordance with their course progress policies.
  • A copy of the provider’s written notification to report the student should be kept on the student’s file. A sample notice (pdf, 599kb) (rtf, 70kb) of intention to report a student is available.

 

10.7  

Where the student has chosen not to access the complaints and appeals processes within the 20 working days period, withdraws from the process, or the process is completed and results in a decision supporting the registered provider, the registered provider must notify the Secretary of DEEWR through PRISMS of the student not achieving satisfactory course progress as soon as practicable.

 

  • The student has 20 working days in which to access the complaints and appeals process of the provider. This does not mean that the complaints/appeals process must be finalised within 20 working days.
  • Standard 8.4 requires that if a student chooses to access the provider’s complaints and appeals process, the provider must maintain the student’s enrolment while the complaints and appeals process is ongoing. For further information about complaints and appeals, please see Standard 8.
  • DIBP will consider all the information available and if they decide to consider cancellation, DIBP will send a Notice of Intention to Consider Cancellation (NOICC) prior to a decision being made to cancel the students visa.  Students will be given an opportunity to respond to the NOICC and explain their situation. The student does not need to attend a DIBP office.

 

 

Common questions and answers

Please note: The principles in the examples below can be applied to all sectors.

Compassionate or compelling circumstances and appeals

 

Q

What happens when the student’s external appeal citing compassionate or compelling circumstances goes against the student and the provider reports the student?

A

When the appeal supports the provider’s decision to report the student, the provider details the breach in PRISMS. The information is electronically transmitted to DIBP. DIBP will consider all the information available and if they decide to consider cancellation, DIBP will send a Notice of Intention to Consider Cancellation (NOICC) prior to a decision being made to cancel the student's visa.  Students will be given an opportunity to respond to the NOICC and explain their situation.

 

 

 Intervention strategy

 

Q

What happens when a student is identified as being at risk of not making satisfactory course progress?

A

A provider must follow its policy for monitoring course progress and implement an intervention strategy to assist the student to complete the course within the registered course duration. An intervention strategy must have procedures for identifying and assisting students at risk of not meeting course requirements at the end point of each study period, or earlier if outlined in the provider’s course progress policies and/or intervention strategy. Providers must have documented procedures for contacting and counselling students; arrangements to assist students to satisfactorily complete their course; and information about how and when the intervention strategy is activated. The intervention strategy should be tailored to each student’s needs whether academic or personal. Providers are advised to document the intervention strategy and have a copy signed by the student placed on the student’s file.

 

 

A student is identified as at risk of not making satisfactory course progress

Tora was studying for a Diploma of Animal Husbandry at the Northern Agricultural College. At the end of the first term, the Director of Studies compared Tora’s progress with the standard for the course outlined in the provider’s course progress policy.

The college's course progress policy states that the college will implement its intervention strategy where the student has failed or is deemed not yet competent in 40 per cent or more of the units attempted in any study period. As Tora was assessed as competent in less than 60 per cent of the units in her first semester, the college's intervention strategy was implemented.

The first step in the college’s intervention strategy is to interview students at risk of not making satisfactory course progress to find out what factors have led to the student’s progress concerns. In the interview it became clear that Tora had experienced severe personal problems during the first term, so the college arranged for personal counselling and assistance on a regular basis over the second term. The college also allowed Tora to drop one unit in the second term. All of these strategies were agreed to by Tora, and a signed copy of the strategy was placed on her file.

 

Note:

  • The provider’s course progress policy and procedure clearly sets out the point at which a student would be considered as not making satisfactory academic progress.
  • An intervention strategy assists students and is activated at the end point of a study period. However, a provider may implement the intervention strategy at any point before to the end of a study period as long as it is outlined in the provider’s course progress policy and/or intervention strategy.
  • Note that the college chose to set a higher progress threshold for intervention than is required under the National Code 2007. Providers may choose to implement their intervention strategy at a higher level of progress than the minimum 50 per cent level as long as this is documented in their course progress policies and procedures.
  • Tora was allowed to drop one unit in her second term, as this was a recognised intervention measure in the college’s intervention strategy. However, a student must complete study within the length of the Confirmation of Enrolment (CoE), where the CoE does not exceed the registered course duration. A course may be extended under Standard 9.2 b. where an intervention strategy has been implemented.

 

Q

Can a provider report a student for failing to make satisfactory progress if the provider has not implemented an intervention strategy?

A

No. Providers are required to have and implement a documented intervention strategy for assisting students at risk of making unsatisfactory course progress. The intervention strategy must be allowed to run its course, and the student must be identified as failing to make satisfactory progress before the reporting process may begin.

 

 

 

Q

What are some examples of appropriate intervention strategies?

A

Providers must determine their own intervention strategies, bearing in mind that a variety of measures may be required to meet different student needs. Intervention strategies may include, but are not limited to:

  • academic skills support
  • additional English support
  • additional tutoring/study group
  • increased monitoring
  • a mentor programme
  • personal counselling
  • placement in a more appropriate class; and
  • reduction in course load.

 

 

 

Q

For the purpose of implementing an intervention strategy, how should providers assess ‘50 per cent of units’ when not all units are weighted equally?

A

It is the provider’s prerogative to define the content of its course progress policy as long as it meets the requirements of Standard 10. Standard 10.2 states that appropriate documented course progress policies and procedures would specify:

  • requirements for achieving satisfactory course progress
  • process for assessing satisfactory course progress
  • procedure for intervening for students at risk of failing to achieve satisfactory course progress.

Under Standard 10.5 providers must implement an intervention strategy for students at risk of not meeting satisfactory course progress requirements. At a minimum, the intervention strategy must be activated where the student has failed, or is deemed not yet competent, in 50 per cent or more of the units attempted in any study period. This threshold is a minimum. Providers are welcome to set an earlier, or lower, threshold to activate the intervention strategy.

For example, Provider A specifies unsatisfactory progress is failing 50 per cent or more credit points (not units studied) undertaken in two consecutive semesters.

In a study period a student is studying 3 units: 2 units of 6 credit points each and 1 unit of 12 credit points. If the student fails the 12 credit point unit, the student has failed 33 per cent of units but 50 per cent of the credit points.

The minimum requirement under Standard 10.5 – is for providers to implement the intervention strategy when the student is at risk of not meeting satisfactory course progress requirements as defined by the provider – see 10.2.

The student is clearly not meeting the benchmarks of Provider A’s course progress policy (failing 50 per cent of credit points for that semester), so Provider A must implement its intervention strategy for this student.

 

Unsatisfactory course progress

 

Q

Does Standard 10 specify what constitutes unsatisfactory course progress?

A

Standard 10.2 d. requires the provider to have within its course progress policy a process for determining when a student has failed to meet satisfactory course progress. While the Standard 10 specifies minimum requirements for implementing an intervention strategy, it does not specify minimum requirements for satisfactory course progress.

However, Standard 11 (Monitoring attendance) refers to the Department of Education-DIBP approved course progress policy and procedures which defines satisfactory course progress for the providers who choose to implement this policy. For further details, please see the Department of Education-DIBP approved course progress policy and procedures (pdf, 611kb) (rtf, 107kb). 

 

 

 

Q

Once a student has been identified as not achieving satisfactory course progress, what must the provider do?

A

As soon as possible after the provider has identified the student as not making satisfactory progress, the provider must give the student written notification of its intention to report the student for not achieving satisfactory course progress. The written notice must inform students they may access the provider’s complaints and appeals process within 20 working days.

If the student’s appeal is successful, the provider does not report the student, but rather supports the student in accordance with the provider’s course progress policies and procedures.

If the student chooses not to appeal or the student’s appeal is unsuccessful, the provider must notify the Secretary of the Department of Education through PRISMS of the student not achieving satisfactory course progress. This reporting should occur as soon as possible after the decision to report is finalised.

 

Academic progress policy

 

Q

Can providers use Grade Point Average (GPA) calculations to determine course progress?

A

Under Standard 10.2, providers’ course progress policies must specify the requirements for achieving satisfactory course progress and the process for assessing satisfactory course progress. As providers are responsible for determining how they will assess satisfactory course progress, providers may choose to use the Grade Point Average (GPA) calculations to determine course progress. Similarly, a provider may use other methods of assessing satisfactory course progress as long as these methods are reliable, consistent and stated in the provider’s course progress policy and procedures.

 

 

 

Q

Is it acceptable for an academic progress policy to state that mid-year intake students are allowed three semesters of poor progress before exclusion, but our start-of-year intake students are allowed only two semesters before exclusion?

A

Yes. As long as this arrangement is clearly stated in the progress policy and is made clear to students prior to enrolment.

 

 

 

Q

How do institutions determine 50 per cent failure when research higher degree courses are not structured into classes and graded units?

A

The Department of Education assumes that a research student would have a research plan approved by the research supervisor who assesses progress against this plan. The Department of Education also expects the provider to have some mechanism for regularly monitoring (and where necessary, reporting on) progress, e.g. at the end of each study period research supervisors meet and say ‘this student is on track, this one needs extra help, this one is not progressing satisfactorily’.

When there are no defined subjects against which to measure pass or failure, providers must still implement an intervention strategy for students at risk of not making satisfactory progress. The 50 per cent of subjects point is a minimum only (see Standard 10.5). The Department of Education would expect that the research supervisor and the institution would have appropriate support mechanisms for research students at risk of not succeeding and that these would come into effect as soon as it was clear the student was struggling.

 

The Department of Education–DIBP course progress policy

 

Q

Can providers of non-VET courses use the Department of EducationDIBP course progress policy as their course progress policies and procedures?

A

Yes. Standard 11 allows any provider to choose to implement the Department of Education-DIBP approved course progress policy and procedures (pdf, 611kb) (rtf, 107kb). However, the exemption from attendance monitoring requirements only applies to VET courses for which the Department of EducationDIBP policy has been implemented.

 

Reporting through PRISMS

 

Q

How will providers report a student through PRISMS for not making satisfactory progress?

A

PRISMS will guide providers through the reporting process. To report a student for not making satisfactory progress, providers must go into the Student Course Variation (SCV) screen, and from the drop down list under ‘Reason for Course Variation’, choose Unsatisfactory Course Progress. Once the provider has chosen this, PRISMS will ask questions about the appeals processes to which the provider answers ‘Yes’ or ‘No’. The provider will then be required to fill in comments regarding the situation, and check the student’s postal address. Once these have been entered, a warning will appear to remind providers of the implications for the student visa of a student who is reported as failing to meet course requirements. 

 

 

Notice of intention to report

 

Q

What information should be included in the notice of intention to report?

A

The notice of intention to report should clearly state that the student has breached their visa condition in relation to course progress requirements under Standard 10.

Notices should refer to the student by name, rather than a generic ‘Dear student’, and include the address to which the notice was sent. These details will ensure providers can track to whom and where the notice was sent.

Standard 10.6 states that when a provider informs a student of its intention to report the written notice must:

"…inform the student that he or she is able to access the registered provider's complaints and appeals process as per Standard 8 (Complaints and appeals) and that the student has 20 working days to do so."

 

Q

When I send a notice of intention to report, when should I begin counting the 20 working days?

A

To avoid confusion, providers are advised to include in the notice the date on which the 20 working days commences. Suggested wording:

"…you have 20 working days beginning on in which you may access the College's complaints and appeals process."

The critical issue for providers when sending notices is to allow students the full 20 working days to access the complaints and appeals process if they choose to do so. Consequently, providers should not begin counting the 20 days from the date of the notice or decision to report the student, unless they can demonstrate delivery the same day as the date on the letter/notice.

For ESOS compliance purposes providers can rely on Australia Post advice as to usual delivery times to set the start date of the 20 working days.

Q

If I use registered mail to send the notice of intention to report, when does the 20 working days begin?

A

While registered mail is considered best practice, it is not a requirement under the ESOS Act or National Code. Where a provider chooses to use registered mail, the 20 working days should begin from the time the student signs the delivery slip.

 

Q

Can I use the student's pigeon hole to deliver the notice of intention to report?

A

Yes, but the student should be fully informed of such arrangements prior to any notices being delivered under Standard 10.6. For example, it could be noted in your policies and orientation material. It is good practice for the provider to only use this method where most other correspondence with the student is delivered in this manner.

 

 

 

Q

Can I send a notice of intention to report via email, fax, web-based communication or any other form of electronic communications?

A

Yes, but you must have informed the student via a direct communication or via your publications that written notices under Standard 10.6 will be given by electronic communication. The notice of intention to report must state the date on which the 20 working days period prescribed by Standard 10.6 would commence.

 

 

Compulsory and non-compulsory study periods

 

Q

In some sectors (for example schools) students may commence their studies part way through a study period. If a student has commenced studies part way through a study period, does the provider have to monitor and assess the student’s progress for the purposes of Standard 10?

A

Standard 10.3 requires that providers assess the course progress of the student in accordance with the provider’s course progress policies and procedures at the end point of every study period. Providers who allow students to commence part way through a study period must include in their policies and procedures how they will address course progress monitoring and reporting for such students. When writing these policies and procedures, providers should bear in mind the length of their study periods and whether students who start part way through a study period will have had sufficient study time with the provider for a fair assessment of the student’s progress to be made.

 

 

 

Q

If a student enrols in non-compulsory study periods, does a provider have to assess the student’s performance at the end of this period and consider this performance in its calculations of satisfactory/unsatisfactory progress?

A

Standard 10.3 requires the provider to assess the course progress of the student in accordance with its course progress policies and procedures at the end point of each study period.

If a student is enrolled in a non-compulsory study period, the provider will need to assess the student’s progress in that study period.

If the provider is using the Department of Education-DIBP Course Progress Policy and Procedures, the non-compulsory study period is not counted for the purposes of reporting. If the provider is using its own course progress policy, the provider determines whether or not it will consider non-compulsory study periods towards progress reporting.

 

 

Connections

 

 

Information

For further information about this Standard, please visit the Australian Education International and Department of Immigration and Border Protection websites.